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Whoopsie! GBE Bites Off More NIETC Corridor Than It Can Chew

7/2/2024

Everyone is incensed by the U.S. Department of Energy's preliminary 5 mile wide National Interest Electric Transmission Corridor (NIETC) that was magically centered on Invenergy's proposed Grain Belt Express transmission line. How and why was that preliminary designation made? And for what purpose?

A NIETC's purpose is to designate a geographic area where one or more transmission projects serving the "national interest" can be sited. A transmission project inside an NIETC can apply for a federal permit and eminent domain if its state application is denied. NIETCs are a way to overturn a state decision you don't like.

But GBE claims to have all the state approvals it needs. So, why the corridor?

Why is it 5-miles wide?

And what ever happened to GBE's Environmental Impact Statement being prepared by the U.S. Department of Energy's Loans Program Office to facilitate a "get out of debt free" card provided by taxpayers if GBE cannot repay its loan?

All these questions (and more!) were answered recently, and the answers did not come from DOE. DOE has put its interactions with greedy transmission developers under lock and key. No, the information came from another (anonymous) source whose accuracy can be trusted.

The Midwest Plains Preliminary NIETC was submitted to DOE by GrainBelt Express (GBE) as a National Interest Electric Transmission Corridor because of the federal funding opportunities that a NIETC designation opens up, as well as the potential last resort option of the use of federal backstop siting authority in States where the initial state approval is currently under appeal, such as Illinois. The corridor was originally submitted as five miles in width because GBE thought that it had to be at least wide enough to encompass two lines.

Because of all the stink you made, GBE has submitted comments to DOE requesting that the corridor be substantially narrowed to no wider than is necessary to site just the GBE line.

But would a narrow, specific "corridor" that only enables one transmission line actually be something that DOE can do? It positively smacks of government graft. Wouldn't a wider corridor give the DOE plausible deniability? It seems like the DOE was only too happy to create a 5-mile wide corridor (which is supposed to be based on DOE's factual transmission needs study, btw, not greedy requests). Who knows what DOE will do with this corridor in the fall. Will they stick with their 5-mile wide corridor, or will they prove that they are nothing more than a corporate puppet by granting GBE's second request to narrow the corridor just wide enough for GBE?

If designated this fall, this NIETC will have to undergo a federal Environmental Impact Study, just like the one GBE is already involved in required by its request for a government loan guarantee. But the study already underway only studies the very narrow GBE corridor. It doesn't study a 5-mile wide NIETC. If the NIETC is any wider than GBE itself, then GBE's EIS will have to go back to start. But perhaps that is required in any instance, since the basis for the EIS and governmental action will have changed completely between a government loan guarantee and a NIETC. You could probably litigate on changing purpose in midstream for a long time. Maybe GBE will have to fund two separate EIS reports, one for each purpose? Each EIS takes a minimum of two years.

Meanwhile, back at the DOE, the right hand has no idea what the left hand is doing. Don't these gals ever see each other in the hallways and stop to chat? Maybe not because they are all likely "working from home". I hear that nobody answers the phone at DOE HQ anymore. Is any work being done in that empty building we pay for?

DOE says the LPO (Loans Program Office) will publish the draft EIS for public review and comment this winter. DOE is plunging ahead with the EIS for the loan, while not even acknowledging another one has to be done for the NIETC designation. At least they're only wasting GBE's money with this duplication of effort. Carry on, ladies!

And here's another thought brought on by the preliminary NIETC designations. GBE's western terminus will be in Ford County, Kansas. We've been told that for years. The story goes that GBE will ship all that untapped wind energy in Kansas to "where it's needed most" (Mars? Polsky's imagination? Lifestyles of the Rich and Famous?). GBE is now asking for approval of two "collector lines" in southwestern Kansas for wind AND solar projects not yet built. See KCC docket 24-GBEE-790-ST available at this link for more info.

Kansas, huh? Then what is the Plains - Southwest NIETC for, and why does it reach its cold little finger up into Ford County Kansas? Is it trying to export even more Kansas wind, or is it importing wind from other states that will be shipped through Kansas on GBE?

Kansas officials who have been falling all over themselves to give GBE whatever it wants because they think it's going to cause massive economic development in Kansas may end up with a massive Dodo bird egg all over their faces if it turns out that Kansas is just being used as another "fly over" state facilitating Invenergy's profit. Who remembers that Invenergy owns "the country's largest wind farm" in the Oklahoma panhandle? Whose idea was this Plains - Southwest corridor, and who is going to profit from it? Invenergy's giant wind farm was planned and construction began (to preserve tax credits) way back in 2018 as part of AEP's ill-fated WindCatcher project that was supposed to connect Invenergy's wind farm to the Tulsa area via a new transmission line AEP wanted to build. AEP did not receive approvals for that scheme and the project was cancelled. And there was Invenergy with the country's biggest wind farm in process and no transmission line to serve it. Invenergy bought the remnants of Clean Line's Grain Belt Express later that same year. Kismet!

Anyhow... maybe, just maybe, the longer this debacle goes on, the GBE koolaid that some of the project's biggest cheerleaders ingested seems to be wearing off. Wakey, wakey, little officials! There's a wolf among your sheep!

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NIETCs Panned by Public

6/29/2024

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Thousands of citizens across the country gave the U.S. DOE their thoughts and opinions about the potential designation of multiple National Interest Electric Transmission Corridors (NIETCs) across the country this week. And it seems like nobody thought it was a good idea, except a handful of clueless congress critters playing politics. I'm going to bet they didn't ask any of their constituents who would be impacted by NIETCs what they thought about it, and they suck up to the political teat at their own peril at the ballot box.

This is probably my favorite line from all the comments I managed to read before they got sucked down into DOE's black hole. This comment comes from the Inskeep family in Kansas.

There hasn’t been a land grab and human expulsion to this degree since the Native Americans were slaughtered indiscriminately and herded off their land.

Congress, the U.S Department of Energy, and the DC political machine never considered the thousands of people impacted by their desire to turn rural America into energy slaves for their glistening cities, nor put it into the context of how it will be remembered by the history books.

The midwestern state farm bureaus submitted excellent comments, and the Missouri Farm Bureau wrote this opinion piece.

These are the Missouri Farm Bureau's comments.

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And these comments came from the Illinois Farm Bureau and a collection of impacted landowners in that state.

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Further east, I submitted these comments on the designation of multiple NIETC segments in West Virginia for the purpose of shipping coal-fired power to Virginia's "data center alley" via new high-voltage extension cords.

Sacrificing West Virginia’s environment and imposing new costs on its struggling consumers for benefit of Virginia’s economy and the profits of the corporations who operate there is the epitome of environmental and economic injustice. Virginia ranks tenth in the list of average salaries by state, with an average annual salary of $65,590. West Virginia ranks 48th on the list, with an average annual salary of $49,170.13 West Virginia is never going to economically catch up with surrounding states if its citizens are forced to pay a significantly larger share of their income to support the economic development of surrounding states.

Read the whole thing here:

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A citizen asked DOE where they could read all the comments that were submitted. DOE's response was

Thank you for your inquiry. DOE will not be making comments received regarding the preliminary list of potential NIETCs publicly available.

This is not a transparent process. DOE is most likely up to no good, but how can we know for sure when the public is shut out of a process that could take their land and destroy their economic well-being? What happened to "transparency" and "public participation"? It's out the window.

Nevertheless, you inserted yourself into a process where you were not welcome. It's the only thing you can do when your government is holed up with special interests and planning to take what's yours. The legal challenges will come later. Thank you to everyone who participated!

What's next? The DOE plans to issue its decision this fall with "draft" designation reports. You'll be allowed to comment on these reports, but DOE will have already made its decision and you'll be in the position of trying to change their mind. Where has democracy gone?

For each corridor that receives a draft designation, the DOE will have to undertake an Environmental Impact Study, which is a multi-year process where they are required to involve the public. But we already know what DOE thinks of public comment, right? They have made that plain. They are in a real big hurry to railroad this process forward before the election in November. Don't forget to vote!

4 Comments

Maryland Piedmont Reliability Project

6/21/2024

15 Comments

Well, here's another particularly noxious transmission project weed! The so-called "Maryland Piedmont Reliability Project" or MPRP. This industry loves its acronyms!

In 2023, regional grid manager PJM Interconnection devised a suite of new electric transmission projects designed to import new electricity supplies to new data centers in Northern Virginia, and for Frederick County's new Quantum Loophole project. Data centers use so much electricity, it's equivalent to large cities sprouting up overnight in previously rural places. New cities need new power supplies, especially because Maryland has been closing all its baseload power plants that run on fossil fuels. Before Maryland's recent plant closures under their "clean energy" plan, the state was importing 40% of the energy it used. Now, it needs even more imports! We're heading toward more than 50% of Maryland's electricity being imported from neighboring states via new high-voltage transmission lines. The only two states in the PJM region that generate more electricity than they use and can export to Maryland are West Virginia and Pennsylvania. The MPRP is importing electricity from southeastern Pennsylvania. Other new transmission projects are exporting electricity from West Virginia's coal-fired plants to Loudoun County's "Data Center Alley. It's nothing more than a series of enormous electric extension cords for data centers. In PJM's planning process, it looked like this:

Frederick County was sleeping the sleep of the uninformed throughout the planning and approval process at PJM. And now it has manifested.

The project was assigned by PJM to New Jersey utility Public Service Enterprise Group. Why them? PJM put its new project requirements out for bid, and PSEG submitted the best project for PJM's needs. PSEG also offered a certain price for the project. There's more to this, but let's stop there for now. Since PJM approved this project and assigned it to PSEG last December, PSEG has been busy devising a route for the project, and now they have finished and want to share it with the public.

PSEG will be holding public "open house" meetings across the project area early next month. See website for details. The "meeting" is hardly an actual meeting though. It's a series of information stations the public is supposed to file through, and you may be handed a card to fill out with your thoughts at the end of the meeting. Each little station will be populated with PSEG representatives, and you can ask them questions. But there is no formal presentation or Q&A session where everyone can hear each question and answer. Go ahead... ask different representatives the exact same question and get wildly different answers. This is why utilities hold these kinds of meetings. They will tell you what they think you want to hear, and not be held accountable for any of it. The main purpose of the "meeting" is to introduce preliminary route maps to the impacted community and receive feedback that could help guide the final route that PSEG files for approval of the Maryland Public Service Commission.

This preliminary route map is floating around social media.

Not a lot of detail, but it's a damn sight better than PJM's initial map as far as determining where they expect this project to go. At the open house meeting next month, PSEG will have the detailed aerial maps that you want to see. The maps may present numerous short route segments that can be pieced together to create a route. They may ask what you think of them. Most people will reject routes that impact them, and may be tempted to champion routes that do not. But, throwing your neighbor under the bus to save yourself is never a good strategy. The community must come together to oppose ANY of these routes. If data centers need new electricity supplies, they need to build new power generators near the data centers, instead of plowing through communities that won't receive any benefit.

The MPRP will likely need new rights-of-way 150-200 feet wide for its 500kV transmission line. The company will ask landowners to sign easements for a one-time "fair market value" payment for just the land in the easement. This gives PSEG the right to use your land, but you will still own it and pay taxes on it. The easement payments are compensation for land you can no longer use, they are not a windfall or profit.

The MPRP website is chock full of propaganda and small bits of information that impacted landowners need to really investigate. For instance, the website says:

The MPRP is a 500,000-volt (500 kV) transmission line designed to respond to growing electric needs in Maryland and the surrounding region. Transmission reliability is key to supporting Maryland’s energy future.

They don't tell you that the project is only necessary because of enormous new data center load. If we didn't build the data centers, or if we built new electric generation near the data centers, this transmission line would not be necessary. It's not for you, it's for data centers. This project also has NOTHING to do with clean energy. It will actually increase carbon emissions in neighboring states that will have to produce more power using fossil fuels in order to import it to new data centers in Maryland and Virginia.

Here's another:

Will PSEG want access to my property before I agree to grant an easement for the project?
PSEG may request prior access to conduct preliminary work such as a survey, delineate wetlands and/or conduct an appraisal to determine the amount of land needed and the value of an easement. In that case, the land owner will be asked to sign a right of entry document allowing PSEG onto the property for only these limited purposes.

State law allows utilities to access property for limited survey purposes before easements are signed. However, PSEG wants landowners to sign a document permitting all sorts of surveying and testing, including things that may harm your property, like core drilling. Think twice about signing this document and giving PSEG unfettered access to do whatever it wants on your property before they have paid you a dime. Maryland law already gives them access for surveying that doesn't harm your property. You don't need to sign any document or give them further permissions.

I also didn't notice the words "eminent domain" on MPRP's website, but that's exactly how they intend to acquire land from unwilling landowners. Easement offers are nothing more than coercion... sign and take the money... or else. When there's no opportunity to say no, it's not voluntary land acquisition.

PSEG's website, its open house meetings, and its permission forms and easement agreements are written in the company's best interest, not yours!

The best use of PSEG's open house meeting will be the opportunity it gives you to meet new folks who are similarly affected by this project and to exchange contact information and hold further meetings among yourselves to share information of interest to landowners who want to defend themselves against this transmission project. PSEG is not from here, it doesn't know your community, and at the end of the day it doesn't care what happens to it. They can't see it from their house in New Jersey!

It's time to circle the wagons, Frederick County! Later this year, PSEG may file an application with the Maryland Public Service Commission. When that happens, you have the right to intervene and become a party to the case that can submit testimony and cross-examine utility witnesses with the goal of convincing the MPSC to deny a permit for this project. There will also be public hearings held by MPSC where you can speak out against it.

Meanwhile, get engaged and stay current on project news. Talk to your neighbors and others in the community who may be impacted. Make a plan. Maybe I'll see you at the open house...

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Landowners Are Not a Problem That Needs Solving

6/16/2024

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Academics who have never had a transmission line proposed across their property are at it again, writing their idiotic "reports" that claim to find the reason why transmission projects draw opposition and are not successful. I've seen many versions of this "save the transmission world" report, and exactly none of them have gotten it right. I think it's because they are inherently biased to think that transmission is "good" and "desperately needed." They believe, deep down in their highly educated souls, that impacted landowners are simply speed bumps on the road to transmission "progress" and that they can figure out new ways to make landowners either acquiesce, or advocate for new transmission to cross their properties. It's nothing but a psy op.

Nobody likes new transmission across their property. NOBODY! Anyone who said transmission was a great idea is either not affected, or their advocacy is being purchased with favorable treatment and ego-stroking (and cash helps, too!).

This new report (see "How Grid Projects Get Stuck" at the bottom of the page) makes conclusions about why the Grain Belt Express stalled out for so long and thinks it has now been successful. Complete lack of accuracy! GBE is in as much trouble now as it's ever been. It's got its corporate head shoved too far up the Biden administration's rear end, hoping for government favors to pull itself out of the dumpster. How much of our tax dollars will the federal government waste on a project that has never been needed?

And, speaking of need, the researchers did not seem to understand what they were told about lack of need for GBE, no matter how much people tried to educate them. GBE, as a merchant transmission project, has not been found needed by regional transmission organizations for reliability, public policy, or economic reasons. If it had any of those benefits and its cost was less than the benefits it offered, a RTO would have ordered the project. No RTO ordered GBE because there was no need for it, not because they are biased against outsiders. If it's not found needed by an RTO, it is not needed. Everyone (but the researchers) understands that. GBE was a speculative venture, a value proposition that never could find any customers who thought it provided enough value to sign a contract. When a project is not needed by a regional transmission planner, and it can't find any customers that think it's an economic value, then it's a completely unnecessary project. It is like McDonald's eyeing your front yard -- GBE wants to take your front yard so it can build a transmission project for one simple reason -- PROFIT. Not because it's needed, or because it provides economic value. Incumbent utilities may be for profit, but they are also public utilities with an obligation to serve. GBE is not a public utility. GBE is only trying to create profit, not serve consumers who need electricity.

The researchers honed in on the disrespectful way Clean Line treated landowners, even mentioning the "Marketing to Mayberry" episode. Skelly gets faulted for his approach to local governments and elected officials before landowners were even notified. That pretty much set the tone, didn't it? How different things might have turned out if Skelly approached landowners first and actually paid attention to their desire for the project to be sited along transportation corridors and buried. It would be operating right now, if it had attracted customers. Instead, Skelly and then Invenergy, just kept dumping hundreds of millions of dollars into a plan that was badly conceived from the beginning. GBE didn't listen to landowners.

The things the researchers think GBE did wrong ultimately don't mean anything though because they picked up on the wrong things, things that wouldn't have made a difference in the long run.

Regulatory institutions are stacked against new players.
Public and regulators' understandings of public interest and public need enable parochialism.
This case highlights a fundamental mismatch between the scale of costs and benefits for long-haul transmission infrastructure.
The traditional model of community engagement, centered around mass meetings and evaluation of alternatives, failed to satisfy either the developer or the community.
Community members are aware of alternative process models and technologies, and they anchor their judgments to their knowledge of these alternatives.
Public opinion favors incumbent entities and processes.

What? Poor, poor, rich little Michael Skelly. Everyone was against him! As they should have been! He was only interested in plundering for profit. Landowners have no use for him, and sent him packing back to Houston. And did our slick willie friend learn anything from his failure? I doubt it, judging from this article about his new company trying to build a transmission line through Montana. SSDD. You can almost smell the failure wafting its way from that article,

State regulators have a duty to consider the public impacts of new transmission. That's not parochialism, that's doing their job. State regulators don't work for merchant transmission companies, or electric consumers in other states. They only work for the public in their jurisdiction.

Projects without benefits will never be accepted by impacted landowners. Even projects with some supposed benefit for "the public" don't matter when it's your home and your money on the line.

Yes, the utility model of keeping the public uninformed until the project and its routes are set in stone is unhelpful. Transmission developers that operate in secret fail in public. But what's the alternative? Would developers approach communities and ask them upfront what kind of project they should build? That is unlikely because the whole public engagement process is built on an enormous misconception. Developers (and researchers) believe that if they can only "educate" (propagandize) impacted communities, that they can turn opposition into support. That is NEVER going to happen. Nobody wants a transmission line. NOBODY. Self preservation is always stronger than bullshit.

The road to success is staring transmission developers, big green transmission advocates, and their government flunkies right in the face. It's a transmission project that does not need any new land. No new land, no eminent domain, no impacts, no opposition.

First of all, we should build new power generation near the power load. When new transmission is needed, it must be routed on existing linear easements, such as road, rail, or underwater. Building a gigantic network of transmission lines for the sole purpose of connecting wind and solar projects to load in distant cities, and trying to use transmission to make up for the intermittent nature of these unreliable sources of electricity is not going to save them. Remote wind and solar is an infeasible money pit. The only thing it's been successful at is making the rich richer.

Landowners who don't want new transmission lines on their property are not a "problem" to be solved.

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DOE's NIETC Information Inadequate for Public Comment

6/15/2024

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The Kansas Heartlander asks if residents are informed enough to comment on the U.S. Department of Energy's National Interest Electric Transmission Corridors proposal?

No, no they are not.

Last week, Missouri Senator Josh Hawley sent a second letter to Secretary of Energy Jennifer Granholm asking for clear and complete information on the NIETC proposal so that his constituents will be informed enough to make comment. Senator Hawley also requested a 45-day extension of the comment deadline.

Senator Hawley said...

Constituents in my state have rightfully complained that the proposal lacks essential information needed to adequately provide comments on the plan. The maps provided are simply not specific enough. Landowners should be notified if the proposed route is going to touch their land. Instead, they are left to guess whether or not their land could be taken by the federal government. And they can only be sure that the corridor is on their land when it is finalized.

That's because the only information the public has is a vague, not to scale map with a line drawn on it. And the DOE has done nothing to notify citizens that they may be in a corridor. DOE has done shockingly little press on its proposal to conscript the land of millions of Americans and turn it into high-voltage electric transmission corridors. If not for the knowledge of a handful of watchdog citizens, DOE would be getting away with it!

It's not like DOE doesn't have the information, it's just that DOE refuses to disclose the information it used to draw its vague maps. DOE solicited "recommendations" for corridors from greedy transmission developers back in December 2023. DOE needs to share the information it received so that citizens can base their comments on the same information DOE will use to evaluate this proposed corridor for designation. Citizens are drawn into a duel without any weapons. It's absolutely shameful!

A future NIETC designation is a land use planning decision that changes the use and marketability of land in perpetuity. Who would buy a home in a NIETC if a future transmission line is planned to destroy it? Who would buy land and build a house in a NIETC that is subject to federal eminent domain? How can farmers plan improvements to their businesses when they have no idea if they will even get their investment back? It's bad enough that Missouri farmers have been threatened with Grain Belt Express for more than a decade, now the DOE is planning more transmission within a 5-mile swath of their remaining properties. On top of that, there is no compensation offered by the DOE for property taken by a NIETC. It's private property taken for public use, without just compensation. The Fifth Amendment to the Constitution prohibits such a taking. It also prohibits depriving citizens of life, liberty, or property, without due process of law, and DOE is shutting down all due process for citizens impacted by its corridor proposal.

Senator Hawley is not afraid to stand up to the DOE and demand due process for citizens. But why are the rest of our elected officials asleep? Bravo, Senator Hawley, and thank you for your work! I hope other Senators are brave enough to join you!

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New FERC Transmission Permitting Rules

5/18/2024

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Let's move on to FERC's new rules for permitting transmission projects in a National Interest Electric Transmission Corridor. FERC also released this rule on Monday. It's another instance of FERC batting away any constructive criticism and doubling down on a bad idea. What's in the water down there anyhow?

If the U.S. Department of Energy designates a National Interest Electric Transmission Corridor, and a transmission project is planned for that corridor, first the transmission developer must attempt to get state permits for its project. In the event that a state denies a permit for a project, then the transmission developer can go to FERC, denial in hand, and ask that FERC overrule the state and site and permit the transmission project anyhow.

This may be the situation with MARL, and any other transmission project that DOE creates a corridor for.

FERC was given authority to site and permit transmission as a "backstop" to state inaction back in 2005. FERC subsequently created rules for its process to do so. When Congress changed the "backstop" law in 2021 to allow FERC to permit even when a state denied a project, FERC released a rulemaking to update its process. During the rulemaking, FERC received numerous comments on its proposed rule and suggestions to make it better. Across the board, FERC rejected most of these changes.

If you find yourself in a situation where the project you oppose ends up before FERC, you're going to need to know the rules for participating in that process.

FERC made only one useful concession between its proposed rule and the final rule issued on Monday. The proposed rule allowed a transmission developer to begin the pre-filing process at FERC at the same time it filed its applications with state commissions. That idea, which was widely panned by states and landowners, would have required landowners to participate in the FERC process at the same time as the state process. Two permitting processes, two sets of rules, two sets of lawyers, two sets of headache. All with the knowledge that the FERC process would become unnecessary if the state approved the project. A complete waste of time. However, FERC dumped that proposed rule and now says that a developer cannot begin its pre-filing until one year AFTER it files its state applications. This gives the state a year to complete its permitting before the FERC process begins. At least you won't be engaging in two permitting processes at the same time. However, FERC did not speak to landowners' question regarding whether the FERC process would proceed while state appeals are pending. For instance, if a state denies, the transmission developer could appeal that denial in state court, instead of engaging in the more expensive and lengthy FERC process. Conversely, if a state approved and the landowners appealed that decision, when would the FERC process begin? This means that this process is still subject to being shaped in practice.

The part of FERC's new rule that is truly awful is its insistence that an "Applicant Code of Conduct" will ensure that the transmission owner has "made good faith efforts to engage with landowners and other stakeholders early in the permitting process" as required by the statute.h

FERC has turned this into a box-checking exercise, not an actual determination of whether the transmission developer has complied with any "Code", as specious as it is. The "Code" is generalized garbage and anyone who has ever had to deal with a transmission developer land agent would be able to drive a truck through its many holes. It's not like any "Code of Conduct" you've ever seen used on any transmission project. In fact, it's so short and devoid of any landowner protections, I can copy the whole thing right here. Applications

Ensure that any representative acting on the applicant’s behalf states their full name, title, and employer, as well as the name of the applicant that they represent, and presents a photo identification badge at the beginning of any discussion with an affected landowner, and provides the representative’s and applicant’s contact information, including mailing address, telephone number, and electronic mail address, prior to the end of the discussion.

Ensure that all communications with affected landowners are factually correct. The applicant must correct any statements made by it or any representative acting on its behalf that it becomes aware were:
(i) Inaccurate when made; or
(ii) Have been rendered inaccurate based on subsequent events, within three business days of discovery of any such inaccuracy.

Ensure that communications with affected landowners do not misrepresent the status of the discussions or negotiations between the parties. Provide an affected landowner upon request a copy of any discussion log entries that pertain to that affected landowner’s property.

Provide affected landowners with updated contact information whenever an applicant’s contact information changes.

Communicate respectfully with affected landowners and avoid harassing, coercive, manipulative, or intimidating communications or high-pressure tactics.

Except as otherwise provided by State, Tribal, or local law, abide by an affected landowner’s request to end the communication or for the applicant or its representative to leave the affected landowner’s property.

Except as otherwise provided by State, Tribal, or local law, obtain an affected landowner’s permission prior to entering the property, including for survey or environmental assessment, and leave the property without argument or delay if the affected landowner revokes permission.

Refrain from discussing an affected landowner’s communications or negotiations status with any other affected landowner.

Provide the affected landowner with a copy of any appraisal that has been prepared by, or on behalf of, the applicant for that affected landowner’s property, if any, before discussing the value of the property in question.

That's all the "protection" you get. As long as a transmission developer files this and says it will follow it, then the box is checked and the transmission developer is "acting in good faith" no matter what it does. "Avoiding" certain behavior is not the same as prohibiting it.

Compare this crappy "protection" to what a group of experienced transmission opponents asked FERC to do in their comments.

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You can expect to experience the same things landowners described in their comments, not FERC's rosy "landowner protections," which do little to actually protect landowners. FERC believes that its "success" permitting natural gas pipelines will ensure landowners are treated fairly in the process. If FERC's future permitting of electric transmission lines is anything like it's prior permitting for natural gas pipelines, we'd all better learn the words to this song:

FERC has chosen to become, in the words of Impacted Landowners, "...just another flashpoint that draws protestors to the Commission’s headquarters because the people understand they have been stripped of the last vestige of any fair process to defend their rights by a federal agency captured by the industry it is supposed to regulate."

See you at FERC, friends. Bring your singing voice!

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Hawley Files Legislation to Stop NIETCs

5/16/2024

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At least there's one Senator interested in helping his constituents with NIETCs! Bravo!

Yesterday, Missouri Senator Josh Hawley sent a letter to DOE Secretary Granholm.

Dear Secretary Granholm,

I write with alarm about your total disregard for farmers in my State of Missouri, as you continue to pander to dark money groups and clean energy interests at the expense of my constituents. Last week, your Department announced new plans to designate a National Interest Electric Transmission Corridor (NIETC) through my state of Missouri, in order to subsidize the flow of wind energy across farmers’ lands.1 This cannot stand. You should rescind these plans immediately.

As you know, the Department of Energy has historically avoided using the heavy hand of the federal government to second-guess state permitting decisions when it comes to electric transmission lines. Courts have narrowly construed your authorities under the Federal Power Act, until Democrats expanded these authorities in the Infrastructure Investment and Jobs Act. Now, you are weaponizing these new authorities to benefit clean energy companies and monied interest as you bulldoze Missouri farmland to make way for transmission lines to carry wind power through the state. Indeed, I find it remarkable that your agency’s lengthy analysis makes no reference to farmers or landowners.

This issue is important to farmers in my state, who have already had to deal with Invenergy’s attempts to build electric transmission lines through farmlands. But at least our state legislature and regulators were able to achieve a new compromise, ensuring that farmers would receive 150% fair market value as compensation for these takings. But by designating a new NIETC in Missouri, you have chosen to federalize this issue and take any future consideration away from state regulators.

There is still hope. Your Department’s announcement only constitutes Phase 2 of the agency’s multistage process for designating NIETCs. I strongly urge you to stop any further consideration of this project and listen to the farmers of Missouri.

Sincerely,
Josh Hawley
United States Senator

Hawley also introduced legislation called the Protecting Our Farmers from the Green New Deal Act meant to:

Prohibit FERC from issuing electrical siting permits where State regulators already have jurisdiction to authorize these projects.
Require FERC to find that any proposed electrical transmission projects it approves minimizes adverse effects on landowners and farmers, adequately compensates them for any loss, and provides benefits to consumers in the State.
Prohibit FERC from reviewing any electrical siting applications where a State regulator has previously denied an application.

That would pretty much put an end to NIETCs.

Let's hope other elected officials follow Senator Hawley's lead and care more about their constituents than they do about the "Green New Deal."

0 Comments

Guidance For NIETC Comments for Midwest-Plains Corridor (GBE)

5/16/2024

2 Comments

Here's a little extra help planning your comments on the U.S. Department of Energy's preliminary Midwest-Plains corridor that follows the route of the Grain Belt Express across Kansas, Missouri, and Illinois.

Even though GBE's right-of-way is roughly 200 feet wide, DOE's National Interest Electric Transmission Corridor is 5 miles wide. FIVE MILES! It will engulf entire farms!

DOE says this corridor is needed for "clean energy" but it fails to even acknowledge Grain Belt Express. Grain Belt Express claims to have all the approvals it needs to build the project already. Why the corridor? Are there going to be more projects routed in that corridor, slowly swallowing up farm after farm? Or is the corridor somehow needed for GBE to get the taxpayer-guaranteed financing it has been seeking?

Designation of a NIETC in this corridor will require an enviromental impact statement for the entire corridor. GBE already has an EIS in process for its federal loan application, but it's just for the narrow right-of-way needed for GBE. A whole new EIS will be required for a 5-mile corridor. Is this why GBE's EIS seems to have been forgotten?

At any rate, here's my advice on submitting effective comments. It's very similar to the EIS comments you may have submitted several years ago. Make sure you have also sent your extension request and letters to elected officials for Step 1.

National Interest Electric Transmission Midwest-Plains Corridor

Guidance for Citizen Participation

DOE’s announcement of proposed corridors begins Phase 2 of its process.

DOE has not provided information about why it is considering a corridor for Grain Belt Express, since the project is claiming to have all the state approvals it needs. It is unclear whether this corridor is a requirement for Grain Belt’s approval of a government-guaranteed loan and how corridor designation would impact the ongoing Environmental Impact Statement process underway by DOE.

Phase 2 allows “information and recommendations” and comment from any interested party and you are urged to submit your comments.

DOE requests information submissions in Phase 2 by 5:00 pm on June 24, 2024. Interested parties may email comments as attachments to [email protected]. You are encouraged to request DOE acknowledge your submission by return email so that you know it was received by the deadline. DOE requests comments in Microsoft Word or PDF format, except for maps and geospatial submissions. The attachment size limit for submissions is roughly 75 MB and may require interested parties to send more than one email in the event attachments exceed this limit. There is no page limit on comments. DOE requests that comments include the name(s), phone number(s), and email address(es) for the principal point(s) of contact, as well as relevant institution and/or organization affiliation (if any) and postal address. Note that there is no prohibition on the number of information submissions from an interested party, though DOE encourages interested parties making multiple submissions to include an explanation of any relationship among those submissions.

DOE will grant party status to anyone who comments in response to the notice of the preliminary list of potential NIETC designations, in the manner and by the deadline indicated above.

Only those granted party status may request rehearing of the DOE’s decision, or appeal the NIETC in court. Protect your due process rights because you don’t know now whether you may want to request rehearing, or appeal an adverse decision. You are an interested party if: you are a person or entity, State, or Indian Tribe, concerned with DOE’s exercise of its discretion to designate a geographic area as a NIETC. Becoming a party does not obligate you to any further action, it only gives you the option of taking further action if you choose.

State in your comments that you are requesting interested party status in accordance with DOE’s NIETC Guidance at Pages 41-42 to preserve your right to request rehearing or appeal a corridor designation. Include comments that may become the basis for your appeal (where DOE is not following the statute). More information about the statute in the long version of this guidance that you may download at the end of this blog.

We are urging interested people to submit comments in two phases. RIGHT NOW and BEFORE THE JUNE 24 deadline.

RIGHT NOW:
To demand public notice and engagement from DOE and set a new comment deadline at least 45 days after the conclusion of the public engagement period. Ask for direct notification by mail of each impacted landowner within the corridor, as well as public notification, including posted notices in all local newspapers servicing the area of each proposed corridor. Request public information meetings, including an online meeting option for those who cannot attend in person. Ask that DOE share all available information on each corridor it is considering, including a narrative description of its boundaries, as well as identification of all transmission line(s) currently planned or proposed for the corridor.

We cannot comment on corridor requests submitted by utilities if we cannot read the requests! We cannot make effective comment on information DOE is keeping secret! It does little good to hold a public comment period for a project that has not provided notice to impacted landowners or disseminated adequate public information.

DOE states, “Early, meaningful engagement with interested parties should reduce opposition to NIETC designation and to eventual transmission project siting and permitting within NIETCs, meaning more timely deployment of essential transmission investments.” But the DOE has not provided any notice or public information about this process, or attempted to engage impacted communities. DOE needs to walk their talk.
Also consider writing to your U.S. Senators and Representatives and asking them to intervene on your behalf to ask DOE for public notice and engagement for the Phase 2 comment period.

See this link for a form letter and help contacting your representatives.

BEFORE JUNE 24:
At the end of Phase 2, DOE will identify which potential NIETCs it is continuing to consider, including the preliminary geographic boundaries of the potential NIETCs, the preliminary assessment of present or expected transmission capacity constraints or congestion that adversely affects consumers, and the list of discretionary factors in FPA section 216(a)(4) that DOE has preliminarily identified as relevant to the potential NIETCs.

DOE invites comments from the public on those potential NIETCs, including recommendations and alternatives.

Phase 2 provides a high level explanation of why the potential NIETCs in the list are moving forward in the NIETC designation process, and you are encouraged to provide additional information on why DOE should or should not proceed with a certain corridor.

Your comments before June 24 should focus on the underlying need within the geographic area as well as “information and recommendations” from DOE’s 13 Resource Reports and other possible topics below in order to narrow the list of potential NIETC designations. DOE also requests information on potential impacts to environmental, community, and other resources within the proposed corridor.

DOE’s 13 Resource Reports: (1) geographic boundaries; (2) water use and quality; (3) fish, wildlife, and vegetation; (4) cultural resources; (5) socioeconomics; (6) Tribal resources; (7) communities of interest; (8) geological resources; (9) soils; (10) land use, recreation, and aesthetics; (11) air quality and environmental noise; (12) alternatives; and (13) reliability and safety.

DOE requests that interested parties provide in their Phase 2 comments the following resource information: concise descriptions of any known or potential environmental and cumulative effects resulting from a potential NIETC designation, including visual, historic, cultural, economic, social, or health effects thereof.

A list of potential topics includes:

Width of proposed NIETC (5 miles for GBE). All properties within NIETC will have the perpetual cloud of potential eminent domain taking for new transmission. This lowers resale value.
Area of NIETC not the right size or in the right place for alternatives or route changes you suggest, such as routing on existing highway or railroad easements.
Federal authorizations needed to build across government land, including impacts to other state or federal land in the corridor.
Need for the project – Do we need new transmission, or would it be a better idea to build generation near load rather than importing electricity thousands of miles from other states? Suggest other options to supply power such as in-state generation from natural gas, biomass, waste-to-energy, nuclear, small modular nuclear, other large scale power generation in close proximity to the need. The federal government can use corridors to force new transmission on states, but cannot force new electric generation on states. Something is wrong with this scenario.
Diversification of electric supply.
Energy independence and security. Defense and homeland security.
National energy policy (not defined).
Are there any customers for the transmission lines proposed for the corridor?
How the corridor may enable for-profit merchant transmission that is not a public utility.
Are there any transmission projects in the corridors that have been approved by a regional transmission organization? (SPP, MISO, PJM).
Maximize use of existing rights-of-way without expanding them, including utility, railroad, highway easements. Reconductor existing lines instead of building new (new wires with increased capacity) without expanding the easement. Buried lines on existing highway or rail rights-of-way, including high-voltage direct current.
Environmental and historic sites.
Costs to consumers. Who will pay for new transmission in corridors? New transmission regionally allocated to consumers will increase electric costs for all consumers. Everyone pays to construct new regionally-planned transmission in these corridors, even if we don’t benefit.
Water use and quality, wetlands.
Fish, wildlife and vegetation impacts. Consider future vegetation management under the lines that includes the use of herbicides, weed killers or other substances toxic to humans, animals or cultivated plantings that are either sprayed on new easements from the air or by on the ground vehicles. Construction vehicles and equipment can spread undesirable, invasive vegetation along the corridor.
Cultural resources – Historic, tribal, other. Socioeconomics – impacts on property, income, quality of life, use of eminent domain.
“Communities of interest” – environmental justice, racial disparities, income disparities, energy burden.
Energy equity and justice: Grain Belt Express has already taken property and disturbed agricultural and other businesses, now the federal government is coming back for 5 more miles of property. The impacts to farms will be devastating.
Geologic – Sink holes, fault lines, abandoned mines.
Soil – erosion, loss of topsoil, loss of vegetation, drainage, compaction, introduction of rock from blasting, destruction of prime or unique farmland, protected farmland, agricultural productivity.
Land use, recreation and aesthetics – changes to land use, homes and farms, conservation easements, parks, churches, cemeteries, schools, airports, visual impacts, public health and safety.
Environmental noise and air quality – construction noise, operational noise, impacts to air quality and emissions caused by project, both during construction and while in operation.

DOE must consider alternatives and recommendations from interested parties. Feel free to suggest as many alternatives as you want in one or more submissions.

DOE will prioritize which potential NIETCs move to Phase 3 based on the available information on geographic boundaries and permitting and preliminary review of comments.

DOE must review public comments, consider recommendations and alternatives suggested.

Want to read more suggestions and tips? Download a longer version of these guidelines with additional information, quotes you can use, and more web resources to explore.

nietc_comment_instructions_gbe.docx
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2 Comments

Guidance For NIETC Comments for Mid-Atlantic Corridor

5/15/2024

1 Comment

Here's a little extra help planning your comments on the U.S. Department of Energy's preliminary Mid-Atlantic Corridor. If you're concerned about a different corridor, such as the Midwest-Plains corridor that follows Grain Belt Express, there will be slightly different guidance, coming soon.

The Mid-Atlantic Corridor roughly follows the path of the MidAtlantic Resiliency Link, or MARL, project that PJM ordered NextEra and FirstEnergy to build last December. It begins at 502 Junction substation in southwestern Pennsylvania and traverses through West Virginia, Maryland, and Virginia on its way to bring coal-fired electricity from West Virginia to Northern Virginia's data centers. It looks like this. The lines on this map may be 200-400 feet wide.

DOE's National Interest Electric Transmission Corridor that corresponds with that project looks like this:

Each line on this map is 2 miles wide.

Here's my advice on submitting effective comments. Make sure you have also sent your extension request and letters to elected officials for Step 1.

Quick Guide for Citizen Participation in Phase 2 Comments

DOE’s announcement of proposed corridors begins Phase 2 of its process. Phase 2 allows “information and recommendations” and comment from any interested party and you are urged to submit your comments. DOE requests information submissions in Phase 2 by 5:00 pm on June 24, 2024. Interested parties may email comments as attachments to [email protected]. You are encouraged to request DOE acknowledge your submission by return email so that you know it was received by the deadline. DOE requests comments in Microsoft Word or PDF format, except for maps and geospatial submissions. The attachment size limit for submissions is roughly 75 MB and may require interested parties to send more than one email in the event attachments exceed this limit. There is no page limit on comments. DOE requests that comments include the name(s), phone number(s), and email address(es) for the principal point(s) of contact, as well as relevant institution and/or organization affiliation (if any) and postal address. Note that there is no prohibition on the number of information submissions from an interested party, though DOE encourages interested parties making multiple submissions to include an explanation of any relationship among those submissions.

DOE will grant party status to anyone who comments in response to the notice of the preliminary list of potential NIETC designations, in the manner and by the deadline indicated above. Only those granted party status may request rehearing of the DOE’s decision, or appeal the NIETC in court. Protect your due process rights because you don’t know now whether you may want to request rehearing, or appeal an adverse decision. You are an interested party if: you are a person or entity, State, or Indian Tribe, concerned with DOE’s exercise of its discretion to designate a geographic area as a NIETC. Becoming a party does not obligate you to any further action, it only gives you the option of taking further action if you choose.

State in your comments that you are requesting interested party status in accordance with DOE’s NIETC Guidance at Pages 41-42 to preserve your right to request rehearing or appeal a corridor designation. Include comments that may become the basis for your appeal (where DOE is not following the statute). More information on the statute in the long version of this guidance that you can download at the bottom of this blog.

We are urging interested people to submit comments in two phases. RIGHT NOW and before the deadline.

RIGHT NOW:
To demand public notice and engagement from DOE and set a new comment deadline at least 45 days after the conclusion of the public engagement period. Ask for direct notification by mail of each impacted landowner within the corridor, as well as public notification, including posted notices in all local newspapers servicing the area of each proposed corridor. Request public information meetings, including an online meeting option for those who cannot attend in person. Ask that DOE share all available information on each corridor it is considering, including a narrative description of its boundaries, as well as identification of all transmission line(s) currently planned or proposed for the corridor.
We cannot comment on corridor requests submitted by utilities if we cannot read the requests! We cannot make effective comment on information DOE is keeping secret! It does little good to hold a public comment period for a project that has not provided notice to impacted landowners or disseminated adequate public information. DOE states, “Early, meaningful engagement with interested parties should reduce opposition to NIETC designation and to eventual transmission project siting and permitting within NIETCs, meaning more timely deployment of essential transmission investments.” But the DOE has not provided any notice or public information about this process, or attempted to engage impacted communities. DOE needs to walk their talk. Also consider writing to your U.S. Senators and Representatives and asking them to intervene on your behalf to ask DOE for public notice and engagement for the Phase 2 comment period.
See this link for a form letter and help contacting your representatives.

BEFORE JUNE 24:
At the end of Phase 2, DOE will identify which potential NIETCs it is continuing to consider, including the preliminary geographic boundaries of the potential NIETCs, the preliminary assessment of present or expected transmission capacity constraints or congestion that adversely affects consumers, and the list of discretionary factors in FPA section 216(a)(4) that DOE has preliminarily identified as relevant to the potential NIETCs.

DOE invites comments from the public on those potential NIETCs, including recommendations and alternatives.

Phase 2 provides a high level explanation of why the potential NIETCs in the list are moving forward in the NIETC designation process, and you are encouraged to provide additional information on why DOE should or should not proceed with a certain corridor.

Your comments before June 24 should focus on the underlying need within the geographic area as well as “information and recommendations” from DOE’s 13 Resource Reports and other possible topics below to narrow the list of potential NIETC designations. DOE also requests information on potential impacts to environmental, community, and other resources within the proposed corridor.

DOE’s 13 Resource Reports: (1) geographic boundaries; (2) water use and quality; (3) fish, wildlife, and vegetation; (4) cultural resources; (5) socioeconomics; (6) Tribal resources; (7) communities of interest; (8) geological resources; (9) soils; (10) land use,
recreation, and aesthetics; (11) air quality and environmental noise; (12) alternatives; and (13) reliability and safety.

DOE requests that interested parties provide in their Phase 2 comments the following resource information: concise descriptions of any known or potential environmental and cumulative effects resulting from a potential NIETC designation, including visual, historic, cultural, economic, social, or health effects thereof.

In addition to the above, a list of potential topics includes:

Expansion of existing transmission easements to add new lines. Expansion will remove all existing buildings, lighting fixtures, signs, billboards, swimming pools, decks, flag posts, sheds, barns, garages, playgrounds, fences or other structures within the expanded easement area. Existing septic systems, leach beds, and/ or wells may not be permitted within the expanded easement area. This would seriously damage host properties or make them uninhabitable.
Width of proposed NIETC (2 miles for MidAtlantic). All properties within the NIETC will have the perpetual cloud of potential eminent domain taking for new transmission. This lowers resale value.
Area of NIETC not large enough or in the right place for alternatives or route changes you suggest, such as routing on existing highway or railroad easements. Federal authorizations needed (crossing Appalachian Trail, C&O Canal), along with impacts to other federal land in the corridor such as Harpers Ferry NHP, The National Conservation Training Center, Antietam Battlefield, to name a few examples.
Need for the project – Do we need new transmission, or would it be a better idea to build generation near data centers instead of importing electricity from neighboring states? This new electric supply is only needed for data centers – suggest other options to supply power such as in-state generation from natural gas, biomass, waste-to-energy, nuclear, small modular nuclear, other large scale power generation in close proximity to the data center load. Building in-state gas generation is constrained by Virginia’s energy policy, which can be changed to avoid new transmission. The federal government can use corridors to force new transmission on states, but cannot force generation choices on states. Something is wrong with this scenario.
Diversification of electric supply.
Energy independence and security. Defense and homeland security.
National energy policy (not defined).
New transmission in the corridor will enhance the ability of coal-fired generators to connect additional capacity to the grid, resulting in increased emissions. Two plants slated for closure have already had their useful life extended (FirstEnergy’s Harrison and Ft. Martin). Imports constrain development of renewable generation in Northern Virginia by importing lower cost coal-fired electricity from other states.
Maximize use of existing rights-of-way without expanding them, including utility, railroad, highway easements. Reconductor existing lines (new wires with increased capacity) without expanding the easement. Buried lines on existing highway or rail rights-of-way, including high-voltage direct current.
Environmental and historic sites.
Costs to consumers. Are the data centers a “consumer” or a beneficiary? New transmission to serve new data centers will increase electric costs for all consumers. Everyone pays to construct new transmission in these corridors, even if we don’t benefit.
Water use and quality, wetlands.
Fish, wildlife and vegetation impacts. Consider future vegetation management under the lines that includes the use of herbicides, weed killers or other substances toxic to humans, animals or cultivated plantings that are either sprayed on new easements from the air or by on the ground vehicles. Construction vehicles and equipment can spread undesirable, invasive vegetation along the corridor
Cultural resources – Historic, tribal, other.
Socioeconomics – impacts on property, income, quality of life, use of eminent domain.
“Communities of interest” – environmental justice, racial disparities, income disparities, energy burden.
Geologic – Karst, abandoned mines.
Soil – erosion, loss of topsoil, loss of vegetation, drainage, compaction, introduction of rock from blasting, destruction of prime or unique farmland,
protected farmland, agricultural productivity.
Land use, recreation and aesthetics – changes to land use, homes and farms, conservation easements, parks, churches, cemeteries, schools, airports, visual impacts, public health and safety.
Environmental noise and air quality – construction noise, operational noise, impacts to air quality and emissions caused by project (increased use of coal in WV to supply power to data centers – Mitchell, Harrison, Ft. Martin, Longview and Mt. Storm coal-fired power plants feed these corridors).
Alternatives – suggest alternatives to this corridor, whether it is different design, different routing, or different power source.
Public safety – hazards to community from weather or operational failure or terrorist attack, health hazards from electromagnetic fields and stray voltage.
Your interaction (or lack thereof) with company applying for corridor. Lack of notice.

DOE must consider alternatives and recommendations from interested parties. Feel free to suggest as many alternatives as you want in one or more submissions.

DOE will prioritize which potential NIETCs move to Phase 3 based on the available information on geographic boundaries and permitting and preliminary review of comments. DOE must review public comments, consider recommendations and alternatives suggested.

Want to read more suggestions and tips? Download a longer version of these guidelines with additional information, quotes you can use, and more web resources to explore.

nietc_comment_instructions-1.docx
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File Type:	docx

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1 Comment

Making Effective Comment on NIETCs

5/11/2024

4 Comments

The U.S. Department of Energy released its preliminary list of National Interest Electric Transmission Corridors (NIETCs) this week.

Interested persons have only 45-days to make comment on these corridors before DOE makes its selections to proceed to the next round. DOE is not doing any notification for property owners within these corridors. It is not doing any public education and engagement, aside from one "listen only" webinar with limited space (sign up now!) There will be no public meetings. DOE is not even sharing the information and recommendations it received from transmission owners (and others) in its Phase 1 information submission window. Their maps are very generalized and have no details. We're supposed to comment on something that we have very little information about within a very short time window. It sort of sounds like DOE doesn't actually want us to comment.

But that only makes me want to comment more. And spread the word like transmission's Paul Revere...

First of all, we absolutely must have more time and information in order to make effective comment on something that threatens to put a cloud on our property in perpetuity. Being located in a NIETC is a designation that will stick with your property, making it the first choice for new transmission projects. How can our government make these kinds of land-use planning decisions that affect literally millions of people without providing notice and giving us information and time to comment?

This is unacceptable!

The first order of business is to demand the notice and information we need. Therefore, I am urging everyone to send a letter to the DOE asking for notice, information and extension of the comment deadline. It's quick and easy... simply download this prepared letter, add your name and other info. and then email it as an attachment to: [email protected].

extension_request.docx
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It is recommended that you include in your email a request for acknowledgement that DOE received your comment, since there is no automatic acknowledgement provided.

One brief explanation: On the bottom of the letter it includes a request for full party status. Being a party doesn't come with any additional duties or expense, it simply allows you to request rehearing or appeal any corridor that impacts you in the future. It does not require you to do so, but it reserves your right to do so if you choose. If you do not request that right, you will have to live with DOE's future decision and cannot take any legal action. It's just a safety measure to protect your rights.

And one more thing... we cannot rely on DOE to act on our requests without a little encouragement, no matter how many we send. Therefore, it is recommended that you also contact your U.S. Senators and Representatives and ask them to demand that DOE provide notice, public engagement and an extended comment deadline for their constituents who are impacted by these huge corridors. Here's your quick and easy guide for getting that done with just a couple clicks:

contact_congress.pdf
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Everyone should get started on this RIGHT NOW so that these requests are in the works early in the comment process. Of course we are also going to encourage everyone to make more substantive comment on the actual corridors that impact them, but that's a post for another day. Stay tuned!

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Whoopsie! GBE Bites Off More NIETC Corridor Than It Can Chew

NIETCs Panned by Public

Maryland Piedmont Reliability Project

Landowners Are Not a Problem That Needs Solving

DOE's NIETC Information Inadequate for Public Comment

New FERC Transmission Permitting Rules

Hawley Files Legislation to Stop NIETCs

Guidance For NIETC Comments for Midwest-Plains Corridor (GBE)

Guidance For NIETC Comments for Mid-Atlantic Corridor

Making Effective Comment on NIETCs

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